Spouses Veroy v. Layague
REITERATIONFacts
The Antecedents: Spouses Leopoldo and Ma. Luisa Veroy were charged with Violation of Presidential Decree No. 1866, specifically illegal possession of firearms and ammunition in furtherance of rebellion. The charge stemmed from the discovery of a .45 caliber handgun with ammunition and materials related to the RAM-SFP group in their Davao City residence. The Veroys, who resided in Quezon City, maintained that they had no knowledge of these items and that their house staff had access to the premises. Procedural History: Following a raid on their Davao City home, where certain items were seized, the Veroys were charged. They voluntarily surrendered and were initially admitted to St. Luke's Hospital for medical reasons. Their subsequent motions for hospital confinement and bail were initially denied by the Regional Trial Court. The petitioners then filed a petition for certiorari, mandamus, and prohibition with the Supreme Court, challenging the denial of their motions and the constitutionality of the decree under which they were charged. This Court initially issued a Temporary Restraining Order and later granted provisional liberty to the petitioners on bail. The Petition: The petition, initially filed under Rule 65, sought certiorari to review the denial of their motion for hospital confinement, mandamus to compel the resolution of their bail motion, and prohibition to halt proceedings based on the alleged unconstitutionality of Presidential Decree No. 1866. The petitioners argued that the decree was unconstitutional, had been repealed by Republic Act No. 6968, and that the evidence seized was inadmissible due to an illegal search. The Supreme Court found the mandamus and certiorari aspects moot due to subsequent resolutions, but addressed the prohibition claim, ultimately dismissing the case against the petitioners.
Issue(s)
Whether Presidential Decree No. 1866, or at least the third paragraph of Section 1 thereof, is unconstitutional for being violative of the due process and equal protection clauses of the Constitution. Whether Presidential Decree No. 1866 has been repealed by Republic Act No. 6968. Whether, assuming the validity of Presidential Decree No. 1866, the respondent judge gravely abused his discretion in admitting in evidence certain articles which were clearly inadmissible for being violative of the prohibition against unreasonable searches and seizures.
Ruling
The petition is granted, and the criminal case against the petitioners for illegal possession of firearms is dismissed.
Ratio Decidendi
On the constitutionality of Presidential Decree No. 1866: The Court reiterated its ruling in Misolas v. Panga that the declaration of unconstitutionality of the third paragraph of Section 1 of Presidential Decree No. 1866 is without legal basis, as it is neither a bill of attainder nor does it provide a possibility of double jeopardy. The decree's provisions do not violate the due process or equal protection clauses of the Constitution. The Court found no merit in the argument that the decree is vague, as the terms used are capable of interpretation and the offense of illegal possession of firearms is a malum prohibitum. On the repeal of Presidential Decree No. 1866 by Republic Act No. 6968: The Court held that Republic Act No. 6968 did not repeal Presidential Decree No. 1866. Applying the cardinal rule of statutory construction, where the language of a statute is clear, its meaning must be determined from the words employed. A perusal of both laws revealed that the legislature provided for two distinct offenses: illegal possession of firearms under PD 1866 and rebellion, coup d'etat, sedition, and disloyalty under RA 6968. These involve different subjects and the latter did not clearly eliminate the former. On the admissibility of seized articles and grave abuse of discretion: The Court found that the articles seized were products of an illegal search, violating the petitioners' constitutional right against unreasonable searches and seizures. While Ma. Luisa Veroy granted permission to search the house, it was only to ascertain the presence of rebel soldiers and did not include authority for a room-to-room search. The police officers had ample time to procure a search warrant but failed to do so. The Court cited cases where warrantless searches were declared illegal when officials had the opportunity to secure a warrant. The seized items, being products of illegal searches, were inadmissible in evidence under the exclusionary principle. The Court emphasized that even in mala prohibita offenses, knowledge or voluntariness is required, and without it, there is no crime. The evidence presented by the prosecution relied on constructive possession, which was not sufficiently proven given the petitioners' residence in Manila and the items found in Davao City.
Main Doctrine
Articles seized in violation of the constitutional right against unreasonable searches and seizures are inadmissible in evidence against the accused, even if the offense involved is mala prohibitum, as the exclusionary principle protects such illegally confiscated items.